Section 2: Ongoing Monitoring

Introduction

Ongoing monitoring occurs in the ordinary course of operations
and includes regular management and supervisory activities and other
actions personnel take in performing their duties to assess the quality
of internal controls and system performance.

Ongoing monitoring occurs every time a Project Manager holds
a discussion or communicates with a subgrantee Project Director
about the project and its performance.

Frequency

Ongoing monitoring can occur daily, weekly, or monthly. Weekly
phone calls may be appropriate if there are problems. Monthly status
meetings might be needed for complex projects or those with significant
problems. Written correspondence, including e-mails, should address
routine matters, unless problems are encountered. Quarterly review
meetings between the subgrantee and the Project Manager are required.

The Project Manager is usually responsible for monitoring
the project throughout the entire grant period, providing technical assistance
as needed, and ensuring that the grant provisions are being followed.
Regular and close communication between the Project Manager and
subgrantee Project Director is encouraged to assist in the early
detection of problems.

Items

Any item related to the progress and management of the grant
might be covered in ongoing monitoring. Although usually limited
to monitoring progress on activities, ongoing monitoring should also
cover the timely submission of complete and correct reports and
required documentation, and close examination of budget issues,
overruns or underruns, problems encountered, procurement procedures,
projected changes, the need for any amendments, best practices,
etc.

Warning Signs

Through on-going and/or on-site monitoring, the
Project Manager should become aware of any warning signs that can
indicate subgrantee noncompliance issues or problems, such as lack
of performance, a change in project direction, or fraudulent activities.

Procedures

To ensure that effective ongoing monitoring is occurring,
the Project Manager should:

routinely set aside time to call
or meet with subgrantee personnel

make a list of issues or questions to cover prior to the
contact, and

ensure that all issues are covered and that a deadline
has been agreed upon to resolve any issues.

Documentation of these contacts, such as notes or e-mails,
should be kept in the project files and made available for monitoring.
Notes or e-mails can also be documented through the submission of On-going
Monitoring Reports through eGrants (See the subheading “Documentation”
below.). Each grant agreement includes a provision that the subgrantee
will arrange meetings with the Project Manager, at least quarterly,
to present the status of activities, discuss problems, and present
a schedule of activities for the following quarter’s work.

Participants

Ongoing monitoring should involve grant personnel with management
or oversight responsibility for the project. In addition to the
Project Director, this would include a financial officer, possibly
an agency grants manager, and any other key project personnel.

Each TxDOT district has an Internal Review Analyst (IRA) who
works for the District Engineer and is trained to monitor and audit
grants. This person is an excellent resource who can possibly assist
the Traffic Safety Specialist (TSS) and provide guidance on laws,
regulations, policies, and procedures.

The TRF-TS Policy and Procedures Coordinator is
another excellent resource, and may be asked to assist if there
is a history of poor performance, or in the case of particularly
large and/or complex grant projects such as grants with State agencies
or STEP projects. The TRF-TS Policy and Procedures Coordinator can
also provide guidance for determining when to request assistance
from management, senior program coordinators, or financial specialists
based upon the nature and severity of problems encountered or if
fraud is suspected.

Documentation

Originals of all checklists, reports, and correspondence must
be documented in the eGrants file of record maintained by TRF-TS.
A note to the file should be provided to document meetings and discussions.
This documentation becomes important during the course of the project
in case of changes in project activities, budget, or grant personnel.
The documentation is also important at the end of the project since
it is used to evaluate project and subgrantee performance.

To document on-going subgrantee monitoring activities, Project
Managers should create and submit an On-Going Monitoring Report
in eGrants. The subgrantee monitoring reports can be found by viewing
a subgrantee’s grant in eGrants. “Subgrantee Monitoring” can be
found under “Examine Related Items.” The procedures for completing
the on-going monitoring report are: